SIFMA submitted a comment letter to the Securities and Exchange Commission (SEC) regarding the removal of ratings and issuer diversification proposal for 2a-7 funds.

SIFMA respectfully urged the SEC to carefully consider SIFMA’s comments to ensure clarity when eliminating references to ratings in Rule 2a-7 and to ensure that the changes to Form N-MFP require reporting only of pertinent information.

SIFMA also urged the SEC to retain the exception to issuer diversification testing for securities with a guarantee by a non-controlled person of the issuer, to avoid a portfolio management constraint that will provide no clear benefit.